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JAN- 5-95 THU 11:54 Y U3 <br /> •r r/ <br /> FIRST CAUSE OF ACTION <br /> Try 1 <br /> VIOLATION OF HEALTH AND SAFETY.. <br /> 2 <br /> CODE SECTION 25298 <br /> 3 <br /> (UNDERGROUND STORAGE TANKS) _ <br /> 4 <br /> 7. Plaintiff is informed and believes and based on such <br /> 5 <br /> information and belief alleges that beginning at an exact date <br /> 8 <br /> that is unknown to plaintiff, but within five (5) years (CCP <br /> 7 <br /> 5338.1) prior to the filing of this complaint, defendants have <br /> 8 <br /> violated Health and safety Code Chapter 6.7, including but not <br /> 9 <br /> limited to: <br /> 10 <br /> 7a. Failure to obtain permit to operate underground <br /> 11 <br /> storage tank in violation of California Health & Safety Code 5 <br /> 12 <br /> 25284 (a) ; <br /> 13 <br /> 7b. Failure to make necessary corrections to come into <br /> 14 <br /> permit compliance in violation of California Health and Safety <br /> 15 <br /> Code 525284(d) (e) ; <br /> 16 <br /> 7c. Failure to equip underground piping with an automatic <br /> 17 <br /> line leak detector on or before December 22, 1990, in violation <br /> 18 <br /> of California Health and Safety Code 525292(e) (1) ; <br /> 19 <br /> 7d. Failure to provide evidence of financial <br /> 20 <br /> responsibility in violation of California Health and Safety Code <br /> 21 <br /> 525292.2(x) ; <br /> 22 <br /> 7e. Failure to properly monitor and failure to maintain <br /> 23 <br /> monitoring records in violation of California Health and Safety <br /> 24 <br /> Code 525293(a) ; <br /> 25 <br /> 7f. The owner has failed to provide a copy of the permit <br /> 26 <br /> n to operator in violation of California Health and Safety Code <br /> 27 <br /> 525293(b) ; <br /> 28 <br /> 3. <br />